I work in customer service for the Credit Card department of a national bank. There seems to be some opposing viewpoints about crediting fees & finance charges to an account if the cardholder doesnt receive the statement for that month, and consequently doesnt make a payment on time. Our CAMS department which handles written correspondence waives all fees & finance charges if a cardholder writes in contesting them for non-receipt of statement. This is as they should do per Reg Z. It seems though that since we accept phone calls, some contend in our department that we are not obligated to waive fees & finance charges as it isnt a written dispute over a billing error, or that since the customer doesnt ask specifically to waive them due to non-receipt we are not obligated to do so. Personally I inform the cardholder that since they didnt receive the statement, all fees & finance charges will be waived regardless of the account profile, CBS score or any other circumstances. What is the correct interpretation for this situation?

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Our CAMS department which handles written correspondence waives all fees & finance charges if a cardholder writes in contesting them for non-receipt of statement. This is as they should do per Reg Z.

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Where in Reg Z does it say you have to refund under these circumstances? I saw where if the cardholder disputes on that basis you have to treat it under the guidelines of a billing dispute, but no where did I see you were required to refund. If you are required to refund, guess what, my future billing statments are going to msyterisously disappear.(Just kidding)

I agree, this is a good PR move, if it's not taken advantage of by the same customers, but unless I missed something I do not think you are required to refund.

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What is the correct interpretation for this situation?

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Unless the dispute is in writing you are under no obligation to process the dispute. (Again may be good PR)

I would also be on the lookout for CSR's who tell customers that receipt of a statement is a courtesy, not a right, and the lack of a statement does not relieve the obligation. Can't tell you how many times I have heard this one in QA's and call center visits.